United States Environmental Protection Agency, Region 9

Air Division

Technical Support Document

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

Antelope Valley Air Quality Management District’s

Rule 1134, Stationary Gas Turbines

Prepared by: Idalia Perez

December 2011
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Antelope Valley Air Quality Management District (AVAQMD)

Submitted Rule

AVAQMD Rule 1134, Stationary Gas Turbines

 Amended: January 19, 2010

 Submitted: July 20, 2010

 Determined complete: August 25, 2010

Previous Rule Submittals

There are no outstanding submittals of Rule 1134.

SIP-Approved Rule

 Adopted: December 7, 1995

 EPA approval: November 1, 1996 (61 FR 56470)

Rule Summary

Rule 1134 regulates emissions of oxides of nitrogen (NOx) and carbon monoxide (CO) from

stationary gas turbine systems with ratings equal to or greater than 0.3 MW.

The emission limits in the Rule are in Table 1 (Section C) and are shown below:

Control Operating 

hours per year

Rating 

(MW)

NOx limit (ppm @ 15% O2) CO limit (ppm 

Gas fuel Liquid fuel @ 15% O2)

SCR + DLN > 877 > 10 5 25 200

DLN > 877 2 – 10 25 65 200

SCR (no DLN 

available)

> 877 2 – 10 35 65 200

DLN > 877 < 2 42 50 250

SCR or DLN < 877 > 10 25 42 200

Any (fired on 

digester and/or

landfill gas)

any 0.3 – 10 25 N/A 200

The rule language includes definitions (Section B) and exemptions (Section D). Monitoring, 

recordkeeping and reporting requirements are contained in various provisions in Sections E, F,

G, H and I.

Impact on Emissions

According to documentation sent along with the rule submittal, the District does not expect a 

reduction in emissions due to the implementation of this rule because there are no existing 

sources affected by the rule. The only turbine currently located in the District is a microturbine 

that is below the size threshold for Rule 1134 and is hence not subject to the rule.

Rule Evaluation Criteria 

We have primarily used the following three criteria to evaluate Rule 1134:
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Rule Stringency Section 172(c)(1) of the Clean Air Act (CAA) requires nonattainment 

areas to implement all reasonably available control measures (RACM), including such

reductions in emissions from existing sources in the area as may be obtained through the 

adoption, at a minimum, of reasonably available control technology (RACT), as 

expeditiously as practicable. Ozone nonattainment areas classified as moderate or above 

must require RACT for all major sources of NOx. CAA § 182(b)(2) & (f); 40 CFR § 

51.912(a). The AVAQMD regulates an ozone nonattainment area classified as moderate 

for the 8-hour NAAQS and severe-17 for the 1-hour NAAQS (see 40 CFR part 81), thus 

Rule 1143 must fulfill RACT requirements for NOx.

Enforceability CAA section 110(a)(2)(A) requires that regulations submitted to EPA for 

approval into a State Implementation Plan (SIP) must be clear and legally enforceable. 

SIP Revisions CAA section 110(l) prohibits EPA from approving any SIP revision that 

would interfere with any applicable requirement concerning attainment and reasonable 

further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA 

section 193 prohibits the modification of any SIP-approved control requirement in effect 

before November 15, 1990, in a nonattainment area.

Guidance and policy documents that we used to define specific enforceability and RACT

requirements include the following:

 Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the “Blue 

Book”), US EPA, OAQPS (May 25, 1988).

 Guidance Document for Correcting Common VOC and Other Rule Deficiencies, EPA 

Region IX (August 21, 2001, the “Little Bluebook”).

 State Implementation Plans; General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 

28, 1992).

 State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990 (the “NOX

Supplement to the General Preamble”), US EPA, 57 FR 55620 (November 25, 1992).

 Alternative Control Technology Document, NOx Emissions from Stationary Gas 

Turbines, US EPA, 453/R-93-007 (January 1993)

http://www.epa.gov/ttncatc1/dir1/gasturb.pdf

 Determination of Reasonably Available Control Technology and Best Available Retrofit 

Control Technology for the Control of Oxides of Nitrogen from Stationary Gas Turbines, 

California Air Resources Board (May 18, 1992)

http://www.arb.ca.gov/research/apr/reports/l3092.pdf

 Status Report on NOx Controls for Gas Turbines, Cement Kilns, Boilers, and Internal 

Combustion Engines; Northeast States for Coordinated Air Use Management 

(NESCAUM, December 2000) http://www.nescaum.org/documents/nox-2000.pdf

Evaluation of Rule Stringency

We believe Rule 1134 implements RACT for Antelope Valley for reasons including:
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- The 1993 ACT provides technical information including control techniques and 

achievable controlled NOx emission levels from stationary gas turbines. Rule 1134

requirements are in alignment with levels of controls that the ACT shows are 

achievable. 

- Rule 1134 requirements are more stringent than those determined to be RACT in the 

1993 ARB RACT/BARCT determination.

- The limits in the rule are consistent with what the 2000 report by NESCAUM 

determined to be feasible for retrofit installations. 

- The limits in the rule are comparable to limits in other Air Districts in California (e.g. 

San Joaquin Valley Unified APCD Rule 4703).

Since no CTG has been issued recently for this activity, we do not have clear national guidance 

defining presumptive RACT. However, we believe the analysis summarized above sufficiently 

demonstrates that Rule 1134 implements RACT. 

Evaluation of Enforceability and SIP Revision Criteria 

Recordkeeping and other compliance provisions in the rule ensure that the requirements are 

adequately enforceable. 

The submitted rule has a wider applicability and more stringent emission limits than the currently 

SIP approved rule, thus strengthening the requirements of the SIP. Therefore, we propose to 

determine that a approval of the submittal would comply with CAA sections 110(l) and 193 

because (1) the proposed SIP revision would not interfere with the on-going process for ensuring 

that requirements for RFP and attainment of the NAAQS are met, and (2) the submitted SIP 

revision is more stringent than the existing SIP requirements. 

Suggested Rule Improvements

Although not currently basis for rule disapproval, EPA recommends that the AVAQMD make 

the following improvements in the next revision of Rule 1134.

1. The exemption for Chemical Processing Gas Turbine (Section (D)(1)(c)) should be 

eliminated or further explained. This is not currently a basis for rule disapproval as there 

are no major sources in the AVAQMD that are subject to this exemption.

2. To facilitate compliance determinations, we recommend amending the rule to require that 

all testing and other records be maintained for 5 years.

Recommendation

Based on the discussion above, Rule 1134 fulfills relevant Clean Air Act requirements for SIP 

approval and EPA staff recommends approval of AVAQMD submitted Rule 1134 for 

incorporation into the California Applicable SIP.

Other References

1. SIP approved Rule, amended December 7, 1995

2. Submitted Rule 1134

3. Staff Report, dated January 19, 2010